Community Behavioral Health (CBH) is the City of Philadelphia’s behavioral health managed care organization, run under the Department of Behavioral Health and Intellectual disAbility Services (DBHIDS), and the only HealthChoices BH-MCO for Philadelphia County. Medicaid ABA in Philadelphia is IBHS-ABA under 55 Pa. Code Chapters 1155 and 5240, delivered only by CBH “ABA-designated” providers.
All IBHS-ABA needs prior authorization at CBH, including the first authorization. It is just light at the start: ABA Initial Assessment (100 units, 30 days) and ABA Initial Treatment (200 units, 45 days) need only a written order. Every later request needs a packet with the written order, a cross-setting assessment with an FBA and/or skills assessment, and a signed ITP whose schedule tables CBH treats as the request itself. The 2025 “IBHS/ABA realignment” capped authorizations at six months, required at least two parent/caregiver training goals, added psychologist review for children with an IEP and for anyone over 12, and limited BHT-ABA to 32 units a day.
CBH’s member handbook lists “IBHS Applied Behavior Analysis (ABA) Services — Prior Authorization Required: Yes”, and the provider manual’s authorization grid says: “For ABA-Initial Assessment and ABA-Initial Treatment, only WO is required. All concurrent requests require WO, IBHS Assessment including FBA and/or Skills Assessment, and Individual Treatment Plan (ITP).” There is no no-auth or registration-only path for ABA at CBH; the easy part is only the first two authorizations.[18][1][5][6][11][12]
Since February 23, 2025 (Bulletin 25-05), CBH authorizes “IBHS Assessment - ABA: 100 units for 30-day duration” and “IBHS Initial Treatment - ABA: 200 units for 45-day duration”. For those two it will backdate up to five business days if the written order specifies a start date (Bulletin 25-19). From June 15, 2025 it will not backdate any concurrent IBHS authorization. A request made after the last covered date is treated as a new initial request, and continuation rights will not apply if the parent grieves a denial.[18][1][5][6][11][12]
Since January 1, 2024 (Bulletin 23-26), CBH “will consider this section of the ITP as the authorization request” and approves up to the service types and hours in the ITP, as long as the written order covers them. Every ITP must include two tables: a weekly “Schedule of Direct ABA Services” by home/school/community, and “Recommended Services per Month” by service type (BCBA, BC, ABC, BHT) with location breakdown and dates. Up to 160 BHT-ABA hours a month is “within the established medical necessity guidelines” (Bulletin 23-08); above that, CBH wants the full IBHS assessment and ITP.[18][1][5][6][11][12]
Bulletin 25-25 (July 31, 2025) and the September 2025 FAQ changed how CBH reviews ABA. For requests reviewed from September 1, 2025, “CBH will not authorize IBHS services unless the ITP includes at least two parent/caregiver training goals and minimal monthly parent/caregiver training sessions” (weekly is best practice). CBH does a medical-necessity review for every youth with an IEP and every youth over 12, with a psychologist or physician advisor involved. New July 2025 medical necessity criteria cover ABA Early Childhood Intensive Treatment (ABA-ECIT) and ABA 1:1 in a center. From October 1, 2025, BHT-ABA is limited to 32 units a day, and 1:1 site-based BHT-ABA lines carry the UD pricing modifier.[7][8][9][2]
The October 14, 2025 notice says packets missing a required element (signatures, dates, NPI and PROMISe IDs on the written order, a signed cross-setting assessment, a signed ITP, recent data) will be marked “Administratively Insufficient”, with 14 days to fix them. Responses to an insufficient finding are written only, at most three pages. Peer-to-peer review is offered after any denial.[7][8][9][2]
The July 2025 MNC also states, under initiation, that ABA requires “a qualified, comprehensive assessment by a clinician with neurodevelopmental disorder diagnoses within their scope of practice” and that “the child must also have a neurodevelopmental disorder that is considered severe and requires ‘very substantial support.’” That is stricter than the state’s any-behavioral-health-diagnosis rule and CBH’s own manual. Expect CBH reviewers to look for severity documentation.[7][8][9][2]
CBH bills ABA by level-of-care code on each provider’s Schedule A: 425-6 Assessment-ABA, 425-7 Initial Treatment-ABA, 425-28 BCBA, 425-29 Behavior Consultation, 425-30 Assistant Behavior Consultation and 425-31 BHT-ABA. Each maps to CPT 97151–97156, and pricing modifiers show the credential: U7 for Behavior Analytic, U8 for Assistant BC-ABA, none for BC-ABA and BHT-ABA. Two staff may bill at the same time only for distinct services with different CPT codes, each documenting the other’s presence. A BCBA’s 97155/97156 alongside a BHT’s 97153 is allowed as a “rare exception” when “all four people are present together (parent, child, BCBA and BHT)”. Supervision and direct observation are never billable.[4][16]
Notes must be in the record “within seven days of the date of service or prior to claim submission, whichever comes first”, and “signed and dated by the qualified clinician who provided the service”. CBH’s February 2026 notice says signatures must be original, and it may recoup for pasted, photocopied or typed-font signatures and for signatures dated before the session ended.[4][16]
CBH contracts ABA Early Childhood programs for children “ages 3-5 who have not yet entered kindergarten” who cannot be served in a less restrictive setting. Children need a primary ASD diagnosis “with Level 2 or 3 severity for either the social communication or restricted, repetitive behaviors and interests domains”. Programs run at least 240 days a year with at least four hours of intensive ABA a day, at about one staff to three children, with at most nine children per room. Only contracted ECIT providers decide whether a child is appropriate.[17][1]
The questions that decide whether a family can start with Community Behavioral Health (CBH) — Philadelphia HealthChoices BH-MCO, and what they have to bring. Each maps onto something intake should ask on the first call.
Under 21. IBHS is available “up through the day before the individual’s 21st birthday” (CBH manual; ABA Performance Standards). ABA-EC/ECIT is for children “ages 3-5 who have not yet entered kindergarten”. There is no minimum age. Since 9/1/2025, every ABA request for a youth over 12 gets enhanced medical-necessity review focused on response to treatment and transition planning.[1][3][17][7]
What must be recent is the written order: “A valid Written Order (WO) from within the last 365 days, based upon a face-to-face encounter” (Bulletin 23-26). For a continued request, an order may be reused if “the last face-to-face meeting with the child is within one year” (Bulletin 25-05). CBH sets no age limit on the diagnosis itself, but its ABA Performance Standards recommend a psychological evaluation “as close in time as possible” to the ABA written order and periodically after.[11][5][3]
The written order may come from “a licensed physician, licensed psychologist, certified registered nurse practitioner or other licensed professional whose scope of practice includes the diagnosis and treatment of behavioral health disorders, and the prescribing of behavioral health services, including IBHS”. Ordering practitioners must be Medicaid-enrolled. The July 2025 ABA MNC adds that the comprehensive assessment must be by “a clinician with neurodevelopmental disorder diagnoses within their scope of practice”. Most ABA written orders are expected to come from CBH’s ABA-designated providers, but a non-designated provider may write one for Initial Assessment and Initial Treatment.[1][2][3]
No diagnostic instrument is mandatory: for an ASD diagnosis, “the Autism Diagnostic Observation Schedule-2 (ADOS-2) [is] preferred, but not required”, alongside norm-referenced tools, rating scales and interviews. On the treatment side CBH does require tools: an FBA for every child prescribed BHT-ABA, and for children with skill deficits a curriculum-based or norm-referenced tool “such as the VB-MAPP, ABLLs, AFLs, or ABAS-3” (Bulletin 25-05). ABA 1:1 in a center needs severe deficits “as evidenced by scores on a structured, norm-referenced tool (e.g., Vineland, ABAS standard scores 70 or below)”.[3][5][2]
An IBHS written order is required on CBH’s current form, which has had options for ABA Early Childhood Intensive and ABA 1:1 in a center since January 2025. It must include the DSM/ICD diagnosis, the maximum hours of each service per month, the settings and measurable discharge markers, plus signatures, dates, the prescriber’s NPI and PROMISe ID. Families may take a valid order to any in-network ABA-designated agency. The member handbook tells families that to receive IBHS they “will need an evaluation from a CBH provider”.[1][9][3][18]
Supplement only. “CBH expects IBHS services to be delivered primarily in person … it should never serve as the primary service delivery method”. It may support contact with collaterals or serve as a rare backup when illness or safety concerns prevent in-person care. The billing guide says telehealth for BHT “does not represent best practice and should be used only in limited instances”, with the reason documented. The 2025 FAQ says telehealth “can be used in a limited way”. Billing (Bulletin 22-16, eff. 9/1/2022): POS 10 when the member is at home, POS 02 elsewhere, informational modifier FQ for audio-only. Get informed consent before any telehealth; texting is not telehealth.[13][4][14][8]
Member handbook: “CBH will decide about non-urgent service requests within two business days of receiving the request”. Requests arriving outside business hours count as received the next business day. If information is missing, CBH must notify the provider “within 48 hours” and allow 14 days (the manual says 14 calendar days for community-based services), then decides within two business days of receiving it. Urgent requests are decided within 24 hours. Since 1/11/2026, IBHS packets must arrive by 2 p.m. to be reviewed the next business day, using the naming format ProviderName.IBHSType.TypeOfRequest.Initials.MM.DD.YYYY. Reauthorization: submit continued requests “from 14 to 30 days prior to the last covered date”; no backdating. Peer-to-peer is available until 2 p.m. the next business day for written-review services such as IBHS. Federal floor: 42 CFR 438.210(d), 7 calendar days standard / 72 hours expedited.[18][1][10][6][21]
“Medicaid is always the payor of last resort and all IBHS levels of care require coordination of benefits, regardless of child diagnosis.” The only exceptions are the CBH-created care coordinator and family peer support. A primary plan’s rejection because the provider is out-of-network “is not a final determination”: the provider may continue unpaid, get a single-case agreement, or transfer the case. Every IBHS claim needs the primary EOB or final determination. Providers get 180 days from the date of service to obtain it and 90 days from it to bill CBH. When the primary authorizes ABA, “CBH will match any authorized services at the same frequency and duration” and “will not render a separate decision of medical necessity, nor is an authorization packet necessary”. CBH reviews as primary only if the primary denies (after its appeals), doesn’t cover the service, or the annual cap is exhausted. TRICARE pays ahead of Medicaid (10 U.S.C. 1079(i)(1)).[15][1][22][23]
Coverage decides whether Community Behavioral Health (CBH) — Philadelphia HealthChoices BH-MCO pays. These decide whether the claim survives: how sessions must be staffed and supervised, what may be billed concurrently, the per-day ceilings, who signs the note, where the service is payable, and whose NPI the claim goes out under.
CBH goes beyond the state rule. BHT-ABA: 1 hour of individual face-to-face supervision a week if working 37.5 hours (counting all hours worked, not just billed), otherwise twice a month. That includes 6 hours of on-site supervision before working alone, and 1 hour of direct observation every 4 months (every 2 months for a BHT with only a high school diploma and RBT training). Behavior Analytic staff: 1 hour a month face-to-face (2 if they supervise assistants or BHTs) and 30 minutes of direct observation every 6 months. No supervisor may have more than 12 FTEs, and at most nine of them BHTs. Non-BCBA BC-ABA staff must be supervised by a BCBA as if they were accruing BACB fieldwork: 5% of hours, at least half in person. Supervision is not billable.[3][4][20]
Allowed only under conditions. Two staff may bill at the same time if “each must be providing a distinct service and may not bill for the same CPT code”, and both notes must record the other’s presence. For a BCBA and a BHT: “There may be occasions where a BCBA is conducting consultation (97155) or parent training (97156) and a BHT is simultaneously providing direct implementation … (97153). This would be allowable, so long as each is providing a unique, billable service, all four people are present together (parent, child, BCBA and BHT)”. A BCaBA (97152/97153 U8) may bill alongside a BHT’s 97153 if the services are distinct. BCBA (425-28) and LBS (425-29) services are “in general … NOT billable to the same member at the same time”. Supervision is never billable.[4]
BHT-ABA: from October 1, 2025, “The maximum number of units that can be delivered per day will be 32 (e.g., 8 hours)”, which CBH says aligns with the Medical Assistance fee schedule. There are also authorization-level caps: Initial Assessment 100 units/30 days and Initial Treatment 200 units/45 days. Requests up to 160 BHT-ABA hours a month fall within CBH’s established guidelines; more than that needs the full assessment and ITP.[7][5][12]
“Progress notes should be signed and dated by the qualified clinician who provided the service”. They must be in the record “within seven days of the date of service or prior to claim submission, whichever comes first”, with start/end times, who was present, the intervention and the response. A BC-ABA doing two CPT services in one visit documents each with its own start and stop times. Signatures must be original (55 Pa. Code § 1101.66a). CBH may recoup for copied, photocopied or typed-font signatures, electronic signatures without a DocuSign/EHR audit trail, and signatures dated before the session ended. The assessment must be signed by the clinician who did it. The ITP must be signed by the parent or guardian (and the youth if over 14), the clinician who wrote it and the ABA clinical director.[4][16][5]
Home, school and community, in the settings named on the written order and ITP. BHT hours are “not separated out by school and non-school locations for authorization”, but claims need the correct POS. Teacher training goes on 97156 with POS 99, because POS 03 is not allowed for that code. CBH calls IBHS “a cross-setting service, delivered in least restrictive and natural environments”, so assessments must observe the child in more than one setting and in every setting where services are prescribed. Center-based options are ABA 1:1 in a clinic (UD modifier on BHT-ABA since 9/1/2025; July 2025 MNC mostly for children not yet school-age with severe behaviors or skill deficits) and ABA-EC/ECIT for ages 3–5.[4][7][2][5]
The contracted, ABA-designated IBHS agency bills the CBH level-of-care codes on its Schedule A. The credential of the person who delivered the service shows in the CPT and pricing modifier: 97151/97155/97156 with U7 for Behavior Analytic (BCBA, 425-28), with no modifier for Behavior Consultation-ABA (425-29), 97152/97153 with U8 for Assistant BC-ABA (425-30), and 97152/97153 with no modifier for BHT-ABA (425-31). Ordering and referring IBHS practitioners must be Medicaid-enrolled, and the manual says “the provider rendering the service must sign all invoices for claims”.[4][1]
Prior authorization. CBH’s member handbook marks IBHS-ABA “Prior Authorization Required: Yes”. The first two authorizations, ABA Initial Assessment (100 units/30 days) and ABA Initial Treatment (200 units/45 days), need only a written order. Every later request needs the written order, the assessment (FBA and/or skills assessment) and a signed ITP.
At most six months since February 23, 2025, even though a written order can be used for up to 365 days. Submit continued requests 14–30 days before the last covered date; CBH no longer backdates concurrent authorizations.
Only as a “rare exception”: each must bill a distinct CPT code (for example 97155 or 97156 alongside 97153), all four people (parent, child, BCBA, BHT) must be present, and each must document the other’s service. Supervision and direct observation are never billable.
Only as a supplement. CBH expects IBHS to be delivered primarily in person; telehealth may support contact with collaterals or act as a rare backup. Bill POS 10 for the member’s home, POS 02 elsewhere, and add FQ for audio-only.
Usually not. When the primary plan authorizes ABA, CBH matches that authorization at the same frequency and duration without a separate medical-necessity decision. It reviews as primary only if the primary denies (after its appeals), doesn’t cover the service, or the annual benefit cap is exhausted.
Payer policies change frequently and vary by plan, state, and funding type. This guide was compiled from the sources above and last reviewed September 2026; it is general information, not billing, legal, or clinical advice. Always verify current requirements against the payer's live policy and a benefits check for the specific member.
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